IRS Written Determinations
Free IRS private letter rulings, technical advice memoranda, and Chief Counsel advice with plain-English summaries and the official IRS release on every page.
No determinations match these filters
Try fewer or different words, check the spelling, or clear the filters to browse everything.
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary.…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary.…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary.…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary.…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary.…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary.…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary.…
Court-approved farm sale preserves trusts' tax treatment
Two irrevocable trusts created before September 25, 1985, owned generally contiguous farm acreage and planned a coordinated sale to a limited partnership owned by a descendant and trust beneficiary.…
Self-settled trust remains grantor-owned and gifts incomplete
A trustor proposed an irrevocable trust for herself and her descendants. An independent distribution adviser could direct distributions to the trustor, while distributions to descendants required…
Dividing grandfathered trusts preserves transfer-tax treatment
A grantor created four irrevocable trusts before September 25, 1985, and no assets were added after that date. The trustees proposed dividing them pro rata into nine trusts, one for each…
Division of a grandfathered trust preserves GST status and tax attributes
A grandfathered trust proposed to divide into three trusts, one for each child and that child's descendants, and to modify the trustee provisions. The IRS ruled that the division and modifications…
LLC recapitalization transferring future profits to sons is a gift
A donor contributed real property to a family LLC and later joined in a recapitalization that allocated all future profit, loss, and asset appreciation equally to her two sons in exchange for their…
Court reformation cures revocable GRAT remainder trust
A grantor funded two GRATs whose remainder beneficiary was intended to be an irrevocable trust for his children. A drafting error instead gave the grantor power to revoke that remainder trust,…
Retroactive trust reformation is respected for GRAT remainders
A grantor funded two GRATs whose remainder beneficiary was intended to be an irrevocable trust for his children. A drafting error instead gave the grantor power to revoke that remainder trust,…
Scrivener-error reformation preserves intended GRAT gifts
A grantor funded two GRATs whose remainder beneficiary was intended to be an irrevocable trust for his children. A drafting error instead gave the grantor power to revoke that remainder trust,…
Reformed remainder trust avoids retained-power tax effects
A grantor funded two GRATs whose remainder beneficiary was intended to be an irrevocable trust for his children. A drafting error instead gave the grantor power to revoke that remainder trust,…
Court-corrected GRAT remainder trust receives tax effect
A grantor funded two GRATs whose remainder beneficiary was intended to be an irrevocable trust for his children. A drafting error instead gave the grantor power to revoke that remainder trust,…
Trust funding is incomplete gift, grantor status partly deferred
An individual proposed an irrevocable family trust whose distributions would be directed through a family distribution committee, sometimes with the grantor's consent, and whose remainder the…
Trust funding is incomplete gift, grantor status partly deferred
An individual proposed an irrevocable family trust whose distributions would be directed through a family distribution committee, sometimes with the grantor's consent, and whose remainder the…
Trust funding is incomplete gift, grantor status partly deferred
An individual proposed an irrevocable family trust whose distributions would be directed through a family distribution committee, sometimes with the grantor's consent, and whose remainder the…
Trust funding is incomplete gift, grantor status partly deferred
An individual proposed an irrevocable family trust whose distributions would be directed through a family distribution committee, sometimes with the grantor's consent, and whose remainder the…
Trust funding is incomplete gift, grantor status partly deferred
An individual proposed an irrevocable family trust whose distributions would be directed through a family distribution committee, sometimes with the grantor's consent, and whose remainder the…
Post-majority trust disclaimers avoid gift tax
A young beneficiary held contingent remainder interests in two irrevocable trusts created before 1977. She proposed disclaiming those remainder interests within nine months after turning 18 and…
Trust construction preserves GST exemption without taxable gifts
A trust created under a will that became irrevocable before September 25, 1985, specifically devised real property to a grandson's issue but did not explain how to distribute proceeds after the…
Sibling approval powers are not general powers of appointment
An irrevocable trust created separate trusts for four children and placed broad amendment, distribution, override, and termination powers in an approval committee made up of those children.…
Joint trust committee powers avoid general power treatment
An irrevocable trust established separate trusts for four children and gave an approval committee composed of those children broad powers over amendments, distributions, appointments, and…
Adverse co-holder interests prevent general appointment powers
A trust for four siblings required an approval committee made up of those siblings to consent to distributions and gave the committee broad amendment, override, appointment, and termination powers.…
Multiple sibling co-holders prevent general appointment powers
An irrevocable trust gave four sibling beneficiaries, acting as an approval committee, extensive control over trust amendments, distributions, appointments, and termination decisions. Committee…
Pro rata trust divisions preserve GST status and tax attributes
Two irrevocable trusts created before September 25, 1985, held assets for four children and their descendants. The trustee proposed dividing each trust pro rata into four successor trusts so…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Retained powers make trust funding an incomplete gift
A grantor proposed an irrevocable family trust whose distribution committee could direct payments and whose grantor retained consent, sole-distribution, and limited testamentary appointment powers.…
Administrative trustee changes preserve trust tax treatment
A settlor and the trustees of four irrevocable trusts created before September 25, 1985, proposed adding a distribution trustee and revising how trustees could be replaced. A beneficiary could…
Trustee changes and unitrust conversion avoid gift tax
Before October 8, 1990, family members used their own funds to buy life and remainder interests in real property, and sale proceeds later entered an irrevocable trust preserving those interests. The…
Administrative trustee changes preserve trust tax treatment
A settlor and the trustees of four irrevocable trusts created before September 25, 1985, proposed adding a distribution trustee and revising how trustees could be replaced. A beneficiary could…
Administrative trustee changes preserve trust tax treatment
A settlor and the trustees of four irrevocable trusts created before September 25, 1985, proposed adding a distribution trustee and revising how trustees could be replaced. A beneficiary could…
Trustee changes preserve estate and GST tax treatment
A settlor created four irrevocable family trusts before September 25, 1985, and proposed adding a trustee responsible for distribution decisions while keeping investment authority with a separate…
Court-approved IRA settlement avoided gift, income, and excise taxes
After two IRA owners died, a beneficiary, an estate, and a charity litigated who owned the inherited accounts. A mediated court-approved settlement determined that the estate and charity had owned…
What these documents are
- Private letter rulings (PLRs): A taxpayer asked the IRS to rule on a planned transaction before doing it. The ruling shows exactly how the IRS applied the Code to those facts.
- Technical advice memoranda (TAMs): The IRS National Office answering a question raised during an audit or other proceeding.
- Chief Counsel advice (CCAs): IRS lawyers advising their own field staff on how to apply the law.
- Determination letters: Rulings on exempt-organization matters, such as whether an organization qualifies under § 501(c)(3) or a foundation's grant procedures pass § 4945.
- Not precedent, still useful: Under 26 U.S.C. § 6110(k)(3) none of these can be cited as precedent. They remain the best public window into how the IRS actually rules on facts like yours, and practitioners read them for exactly that.